Montana-CHEER's Letter to EPA about Worst
Case Scenarios and Proposed New Rule
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a-and-r-docket@epa.gov
Attn: Docket No. A-2000-20
Dear OA&R:
Montana-CHEER is a citizen group dedicated to pollution prevention (P2);
we
have tracked the Risk Management Planning (RMP) rule since it was first
proposed in '93. That first version, with its innovative industrial
safety/P2 elements, would have done more to assure safety than this rule
would, but even the finalized RMP rule and its Right-to-Know (RtK)
elements
would be better for public safety than this proposal That is, not only
has
the RtK been proved in many studies to reduce hazardous chemical use and
to
improve chemical safety; but allowing the RtK to flourish in the RMP
Program will reduce the threat of chemical facility terrorism. This is
because safety improvements (e.g., those resulting from the public
pressure
that the RtK's disclosure of information provides) eliminate, or make
less
easy to release, the hazardous chemical/weapon.
Despite this, in a display of mass stupidity, DoJ and EPA have abandoned
logic to follow the mass hysteria of the era, terrorism (grafted to
cynical
federal pork appropriations). This is not to say the world does not face
a
growing threat of terrorism. But anyone involved in a nuclear family
has
to acknowledge that crack-downs and secrecy inevitably incite children
and
adolescents to challenge . Moreover, part of maturity and just basic
awareness is knowing that the world is not controllable--persons
determined
to execute a chemical terrorism act will surely find a place and a
manner
to do it. Far better to think through this conundrum and act
accordingly.
This is why we call this proposed rule and its law hysteria. Better to
plan and act in an integrated fashion than to focus this hysteria on a
narrow RtK program (accident scenarios posted to the Internet).
The Center for Non-Proliferation Studies definitively analyzed (Tucker &
Sands 'An Unlikely Threat' _Bulletin of the Atomic Scientists_ 7-8/'99,
p.
46-52) the recent ('90-'99) record of chemical & biological weapons
(CBW)
terrorism incidents. Only 27% of the incidents involved actual use of
CBW.
17% of all incidents occurred in the USA, with only one fatality--a
cyanide
bullet assassinating a local California official. Of the 784 CBW
terrorism
injuries identified here, 751 were from salmonella-poisoned food on an
election day (vote fraud). The authors' main conclusion was that
technical
constraints, especially in delivery mechanisms, make an incident of
tens-to-hundreds of fatalities the most likely SEVERE CBW terrorism
scenario. This surely de-emphasizes the perceived threat of chemical
terrorism that politicians and you are giving to the large heavy
industrial
facilities in the RMP Program! Meanwhile, some 250 Americans are
slaughtered every year in chemical accidents that only the RtK could
rapidly reduce. Where are your priorities, man?
Surely an issue as important to the welfare of the country as chemical
terrorism deserves an estimate of how many lives the EPA and DoJ expect
to
save by keeping RMP accident scenarios off the Internet, and of the
lives
saved through full disclosure (including disclosing the assumptions in
your
estimates)? As EPA & DoJ are mandated to protect citizens from
potential
hazards, shouldn't they begin the rule-making process by making such a
comparative estimate!?
We suspect it may be DoJ's culture of domination and police power that
led
to the proposed tracking system for people who request public
information,
regardless of the privacy rights of the U.S. Constitution (which in
Montana's Constitution, the best of the land, are much stronger--it also
guarantees our access to all other records). There is no reason EPA has
to
acquiesce to such a fascist proposal, which is anti ethical to an
important
part of EPA's culture.
Finally, EPA would seem to be unaware of the critical bad precedent this
proposed rule sets. This law would seem to give EPA and DoJ far more
latitude to come up with a rule that actually addresses chemical
terrorism,
and which acknowledges the power of the RtK to reduce hazards and
prevent
pollution.
Tony Tweedale, MT-CHEER
(Coalition for Health, Env. & Economic Rights)
224 E. Pine (2)
Missoula MT 59802-4541
tel (and fax, but must call me first): 406-542-1709
ttweed@wildrockies.org
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